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Comment 1 for Carl Moyer Memorial Air Quality Standards Attainment Program Guidelines (cmp2017) - Non-Reg.

First NameKatherine
Last NameWurtz
Email AddressKwurtz@kewconsultants.com
Affiliation
SubjectRemoving the Operational Requirements for Locomotives
Comment
The CMP Guidelines currently state that locomotives must be in
operation for two years prior to applying for funding.
Unfortunately, this requirement excludes many opportunities to
upgrade locomotives from unregulated to Tier 4 or better. Owners of
locomotives and railroad operators, in the face of this
requirement, will place unregulated equipment in-use before
considering Tier 4 simply because of the cost differential. IE An
unregulated locomotive costs around $250,000 whereas a new Tier 4
locomotive costs upwards of $2,000,000.
CMP should consider the future emissions benefits of reducing or
eliminating this requirement for locomotive projects.

Attachment
Original File Name
Date and Time Comment Was Submitted 2017-03-20 15:37:51

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